PARTNER COMPLIANCE GUIDELINES - for eToro USA (LLC) All you need to know in one place - eToro Partners
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PARTNER COMPLIANCE GUIDELINES for eToro USA (LLC) All you need to know in one place Marketing Affiliate Rules
Below is a checklist of the main rules that should be followed in any financial promotion on your affiliate marketing channel: Always add the USA LLC Risk Warning: 1 eToro USA LLC; Virtual currencies are highly f. Withdrawal g. FAQ volatile. Your capital is at risk. h. Regulation and License i. Customer Service Remember that Etoro offers only real crypto 2 in the USA and no CFDs j. General Risk Disclosure Use only correct information in your reviews/ articles and always keep them updated as per the list Always be fair, clear and avoid misleading 3 statements. below (not exhaustive) - more information can be found at https://www.etoro.com/en-us/ Always mention in your affiliate marketing 4 Affiliates are only permitted to use eToro’s channel which eToro entity you are promoting: eToro USA LLC is a registered money services 6 official marketing materials which can be found business with FinCEN. in the affiliate marketing tools. Any educational materials and/or marketing 5 Use only correct information in your reviews/ articles and always keep them updated as 7 materials and/or related materials created per the list below (not exhaustive) - more by the affiliate to be provided to clients (i.e. information can be found at banners, videos, newsletters, any significant https://www.etoro.com/en-us/ changes to the communication channels of the affiliate etc.), through all of the communication a. Popular Investors channels, should be reviewed and approved b. Our Story (history of eToro) by the Compliance Function/Department of c. Team and Investors eToro, prior to dissemination to clients. Any related requests to this matter should be d. eToro Copy Systems explanation forwarded to your affiliate account manager. e. eToro CopyPortfolios g. Deposits FAQ eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299 1
Any new communication channels and any 8 relevant requests should be immediately AVOID MISLE ADING - ensure that all statements are balanced. Partners can not communicated to the Af f iliate Account place too much emphasis on the benefits Manager and should be pre-approved by the associated with a product without also Compliance Function/Department of eToro. highlighting the relevant risks. Always look for complete, relevant data and add proper Affiliates are not allowed to promote eToro warnings when using data (see section “How 9 via sources other than the ones disclosed to display risk warnings”) and approved by the Compliance Function/ Department of eToro. U N R E A L I S T I C E X PEC TAT I O N S - t h e information shall not include the name of any competent authority in such a way that 10 Affiliates shall not approach, directly or indirectly, any traders and/or potential traders would indicate or suggest endorsement or other than promoting eToro as detailed in approval by that authority of the products these partner guidelines. or services offered by eToro Entities. KEEP THE TERMINOLOGY AND CONTENT Leading Compliance Principles UP TO DATE - all the irrelevant information or old terms need to be replaced and updated (i.e., words like: “Guru, copy fund, OpenBook, high leverage and bonuses/promotions). BE FAIR - do not use misleading headlines Please note that all content and marketing and unfair comparisons. Partners should not materials that include BONUS offerings need hide important information by using small print. Always make sure that you display risk Please note that all content and marketing materials that include warnings in a clear and visible way. Never BONUS offerings need to be immediately removed. promise profits or gains. Do not use any unqualified or absolute statements unless BE CLEAR - about any charges, fees or risks. they can be proved by including source as to where the information is taken from. eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299 2
Examples of Misleading Statements Do not use the statements below: a. Become a successful trader! a. “1 click 60 seconds 85% profit” b. You will make profits! b. “Gain up to 85% return every 60 seconds” c. Make money with the best trader c. “Start your career as a trader right now” d. With eToro, trading is easy d. “Suggestions are great – it is hard not to win” e. Copy the best traders and you will make profits e. “95% return in a few minutes” f. “Our Pro signals have been tested to have over Do not make any false promises Please note that all 65% daily success rates” content and marketing materials that include BONUS offerings need to be immediately removed. g. “What can you do in 60 seconds? Copy* and earn extra money.” Always disclose the sponsorship depending on if h. “Learn how to turn market opportunities into you are an influencer or an affiliate. profit” i. “$10,000 – Get your bonus now.” If posting from abroad, U.S law applies if it’s reasonably foreseeable that the post will affect US j. “Free” consumers. Foreign laws might also apply. k. “Investment”, “investing” Do not incite specific trades eg “Buy bitcoin before it’s too late”. Do not use the word “invest”. Do not suggest the product is “Free” Use risk warnings where appropriate. For example, Cryptocurrencies are highly volatile, be aware of the risks when trading them. Do not make any false promises eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299 3
How to display risk warning? A few examples of CTA: Whenever there is a Call to Action (‘CTA’) for • Trade now Cryptos (i.e., Join now, Trade now, Register, • Sign up Open account, Verify etc), a RISK WARNING • Join now IS REQUIRED. • Buy and Sell • Register Now The disclaimer should be under/next to View Website the button (CTA). It should always be in the language of the WARNING: it should be visible and in website, visible and added to EVERY (CTA). the language of the website. For the small CTA, the disclaimer is: eToro USA LLC; Virtual currencies are highly volatile. Your capital is at risk. (always in bold). For the influencer promoting real crypto, the disclaimer under CTA is: eToro USA LLC. This ad promotes copy. Your capital is at risk. For mix content ( partner promoting different eToro entities) the disclaimer should appear under the US content: eToro USA LLC does not offer CFDs and makes no representation and assumes no liability as to the accuracy or completeness of the content of this publication, which has been prepared by our partner utilizing publicly available non-entity specific information about eToro. Your capital is at risk NOTE: The disclaimers must appear at all times separate from other risk warnings. eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299 4
Influencer VS Affiliate YOUTUBE While advertising on youtube the following Influencer rules should apply: 1. At the beginning of the video, the Definition - Partner with influencers on social #sponsorded needs to appear 10 sec as media who promotes eToro USA LLC per Google’s Ad policies Purpose - Brand awareness Other options: #ad, #advertisement, Includes Paid promotion Promoting Platforms - Social media plat forms such as Facebook, Youtube, Please note that the # can be removed Instagram and more 2. If the video is less than or equal to 30 sec, Who are they? - Celebrities, Bloggers, Media the appropriate time will be 5 seconds at Personalities, Industry Leaders the beginning and 5 seconds in the end. Cost - Influencers are generally compensated with a flat fee (media deal). 3. At the end of the video, a disclaimer should be added in order to mention additional ROI (*return on investment) - Number disclosures that are required under of new followers, social media engagement, applicable laws. Website Traffic, lead generation eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299 5
Affiliate YOUTUBE Definition - Business that promote the While advertising on youtube the following brand/content on their Marketing Channel rules should apply: and receive a commission when leads invest 1. At the beginning of the video, the in the product/service #eToropartner or #eToroambassador needs to appear 10 sec as per Google’s Purpose - Lead generation and revenue Ad policies. growth Please note that the # can be removed Promoting Platforms - Affiliates generally own websites. They usually operate in the 2. If the video is less or equal to 30 sec, the same industry where the audience spends appropriate time will be 5 seconds in the time online beginning and 5 seconds in the end. Who are they? - Companies, Publishers or 3. At the end of the video, a disclaimer should Blog be added in order to mention additional disclosures that are required under Cost - The standard payment is CPA / Revshare applicable laws. ROI (*return on investment) - Average order value, Sales volume, Site traffic eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299 6
ADDITIONAL RESTRICTIONS Please note that if an affiliate cannot amend any of the promotional content of its website in accordance with the above rule, the content shall be required to be removed. NO BONUSES AND/OR ANY TRADING BENEFIT IS ALLOWED - as eToro USA LLC is regulated by FinCEN and cannot offer bonuses whatsoever Only target individuals over the age of 18 Regulatory demands can change often and with no prior notice When this occurs, all promotional materials need to be updated immediately. If you want to make any changes to eToro promotional materials on your site, you must let us know by contacting your affiliate account manager. eToro USA LLC cannot be promoted among Binary Options or associated with Binary Options. Partner Up! In case you need further assistance, do not hesitate to contact your direct affiliate manager and we will be pleased to assist you. We would like to thank you for your collaboration and hope to deliver the best possible experience for all of our Partners! eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299 7
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